REINHARDT, Circuit Judge:
Carl and Virginia Pescosolido appeal from the tax court's decision affirming the Commissioner's determination of tax deficiencies for the Pescosolidos' 1978, 1979, and 1980 tax returns. The tax court agreed with the Commissioner that the Pescosolidos had not sustained their burden of proving that the distribution and disposition of certain Section 306 stock was not in pursuance of a plan having as one of its principal purposes the avoidance...
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